> ----------------------------------------------------------
> Comment 6: Media exemption to 1.1.1
> Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2008Jan/0017.html
> (Issue ID: 2393)
> Status: VERIFIED / PARTIAL/OTHER
> ----------------------------
> Original Comment:
> ----------------------------
>
> I don't fully understand the intention of the "media" exemption to the
> requirement to provide a text alternative for all non-text content
> under SC 1.1.1. I assume it is an attempt to accommodate the
> increasing presentation of audio and video material on the web by
> media not traditionally associated with the web; and, the need to
> balance the accessibility implications of this use with a desire to
> have guidelines that don't impose undue hardship on web proprietors or
> stifle the development of the web.
>
> The terminology used for the Media related exemption is potentially
> ambiguous in the context of the broadcast industry. In particular, it
> appears to address just two distinctly different programming formats,
> "live" and "prerecorded", without providing adequate definitions for
> either.
>
> The WCAG 2.0 Glossary defines the term "live audio-only" as "a
> time-based live presentation that contains only audio" and a very
> similar definition is provided for "live video-only". While these
> definitions might be adequate for a sports broadcast or the coverage
> of an unfolding news event, they do no appear to be sufficient for
> many of the situations faced by the broadcast media today.
>
> The current definitions of live audio-only and live video-only need to
> be expanded in order to meet the real-world needs of the media. The
> phrase 'time-based' is not very meaningful since within the broadcast
> industry all material could be said to be time-based.
>
> The proposed Media exemption does not recognise that sometimes a media
> broadcast (program) might be an amalgam of live and prerecorded
> material. For example, daily live radio programs often contain
> prerecorded segments: In some cases differences in time-zones or the
> schedule of the interviewee require an interview that is presented
> live to be prerecorded; or a live program may incorporate prerecorded
> documentary-style feature segments. With regard to television, it is
> not uncommon to have programs that are presented as live, but which in
> fact consist entirely of prerecorded segments with the only live
> component being the studio presenter who tops and tails them, and in
> some cases even this is prerecorded.
>
> Also, the broadcast of live-to-air (real-time) programs that contain
> absolutely no prerecorded material is becoming increasingly rare; even
> sports broadcasts often now contain prerecorded comments from the
> players. It should be noted, the Guidelines indicate use of
> "prerecorded" audio and video "files" is covered by SC1.1.1, but no
> definitions are provided for the words "prerecorded" and "files". Does
> a prerecorded interview with a player that is stored as an audio file
> require a text alternative within the context of the WCAG 2.0? Or,
> should it be treated as being part of a live audio or video
> presentation and so require only a descriptive label?
>
> The increasing convergence of media is resulting in more and more
> radio and television broadcast material now being presented over the
> web in a variety of ways. For example, ABC Radio National in Australia
> produces live and prerecorded programs and simultaneously "streams"
> all them over the internet at the time of broadcast. 95% of these
> programs are also available as "streamed media on demand", which means
> they can be listened to (but not downloaded) at a different time. In
> addition, over 50 of the daily or weekly programs are available for
> download as MP3 or Podcast files. These are primarily word based
> (non-music) information style programs. I understand the national
> broadcasters in Canada and the UK do something very similar.
>
> The presentation of steamed media on demand and podcasts on websites
> may further complicate the distinction between live and prerecorded
> content. This material, by its very nature, is not live in the sense
> that it is a recording of something that has happened at sometime in
> the past. In some cases however, it might be a recording of a
> live-to-air program and as such may be considered an alternative
> presentation of the initial program and so exempt from the need to
> provide a text alternative; this assumes the initial program is a
> live-only program within the meaning SC1.1.1.
>
> >From a practical point of view, it might be useful to consider making
> a distinction between 'scripted' and 'non-scripted' content since any
> requirement to provide a text alternative for a scripted program is
> likely to be less onerous. However, this should not mean that
> 'non-scripted' material with historical value (e.g. an interview with
> someone concerning a significant world event) is exempt from the
> requirement to provide a text alternative when it is being presented
> on the web for posterity.
>
> Is the intention of the Media exemption to SC 1.1.1, and the
> associated definition, to exempt only live-to-air material from the
> need to provide a text alternative? And consequently, require all
> prerecorded material that is contained in a television or radio
> program to have a text alternative when it is presented on the web. If
> so, the considerable difficulties most broadcasters will experience in
> meeting such a demand is likely to lead to it being generally ignored.
> And, a general refusal by the broadcast industry to conform to a Level
> A Success Criterion could undermine the status of WCAG.
>
> Proposed Change:
> The Glossary should contain definitions for the terms "live" and
> "prerecorded" that relate to the current status of the broadcast
> industry and are likely to be meaningful to people working in the
> broadcast industry.
>
> The Working Group should consider providing greater flexibility in the
> Media exemption to SC 1.1.1, while still retaining the overall desire
> for text alternatives to be provided for television and radio
> broadcast material that is re-presented on the web.
>
> The Working Group might like to consider extending the Media exemption
> to allow programs that are presented in "real-time" (e.g. daily radio
> shows, sports broadcasts, current affairs tv) to contain a percentage
> of "prerecorded" material (e.g. 25%) without the need to provide a
> transcript for that material.
>
> The Working Group might like to consider incorporating a
> time-dimension into the Media exemption for SC 1.1.1. For example, a
> text alternative for non-text content should be provided within 14
> days. This would allow broadcasters sufficient time to prepare text
> alternatives for substantial programs and would enable them to
> continue to provide "streamed media on demand" for 14 days without the
> need to include a text alternative.
>
> ---------------------------------------------
> Response from Working Group:
> ---------------------------------------------
>
> Answering your questions in turn:
>
> 1) No - the media exemption is not in response to any mainstream use
> of media. It is meant for media alternatives to what is already on the
> page where the media alternatives are provided for accessibility
> reasons. This is defined if you click the link for the phrase "media
> alternative for text" in the provision. (note we changed
> "alternative for text" to "media alternative for text" in the
> provision)
>
> 2) Regarding terminology - we have now defined "live" and
> "prerecorded". These new definitions should address your 'sports' and
> 'unfolding news event' question as well.
>
> 3) Correct. All broadcast streaming material would be time based.
>
> 4) We have reworded the 1.2 success criteria to remove the ambiguity.
> If there is mixed live and prerecorded, each follows the guideline for
> its type of media. Although not required, it would of course be
> preferred if the mixed media were to follow the more accessible
> "prerecorded" rules.
>
> 5) With regard to 14 day exemptions and the like, those types of rules
> are outside of the scope of WCAG. WCAG is like a measuring stick. It
> is used to measure the level of accessibility but not to state where
> different levels should be applied.
>
> ------------------------------------------------
> Comment on WG response
> ------------------------------------------------
> I apologise if I misunderstood the intention of the "Media, Test,
> Sensory" exemption provided in the December 07 Draft.
>
> However, I would like the WG to address the issue of the increasing
> use of the web to provide audio and video content that is a mix of
> live and pre-recorded material. As with my response to Comment 3, we
> just can't pretend it doesn't happen. Look at the website of any major
> broadcaster and you will see many examples of what I described. Based
> on your responses to my comments, I assume this must covered by
> Guideline 1.2.
>
> While it is nice to see definitions of "live" and "pre-recorded",
> they are very brief and I don't believe they address the fundamental
> issues I raised. With the exception of streamed media, nearly all the
> broadcast material that different broadcasters make available on the
> web is in essence pre-recorded before it goes on the web, this is the
> nature of the process. It is unrealistic to assume broadcasters are
> going to make transcripts of all this material simultaneously
> available.
>
> When I suggested the WG might look at providing some sort of time
> frame with reference to the need to provide text alternative for
> video/audio material, the Working Group responded, "Those types of
> rules are outside of the scope of WCAG. WCAG is like a measuring
> stick. It is used to measure the level of accessibility but not to
> state where different levels should be applied." I find it hard to
> reconcile this response with the WG willingness to precisely define
> the amount of screen that can flash at a "typical viewing distance"
> when determining the general flash and red flash thresholds: - Is this
> not indicating where different levels should be applied?
>
> To return to the Working Group belief that it is acceptable to remove
> a provision that is "largely ignored", what happens with WCAG if, for
> example many, or all, of the main media organisations in the world,
> feel that complying with WCAG is just not a realistic options.
>
> As I said in my original comment, "a general refusal by the broadcast
> industry to conform to a Level A Success Criterion could undermine the
> status of WCAG."
>
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Response from Working Group (28 March 2008):
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Yes, the examples you provided would be covered by the success
criterion in guideline 1.2. Please also note that the 1.2 success
criteria have been revised to make it clear that the pre-recorded
sections of mixed live/pre-recorded media need to a follow the
pre-recorded provisions.
To answer your question about the difference between time needed to
provide text alternatives for video/audio materials vs. the definition
of the amount of screen that can flash, these are two very different
things. Whether content violates the flash provisions at a typical
viewing distance can be determined by someone with no knowledge of
when the content was created, and the answer will not change over
time.
Our response was intended to illustrate that the guidelines describe
only what is and is not accessible. Issues related to constraints,
expectations or other circumstances regarding the authoring process
may impact whether or not conformance claims can be made, but do not
change whether or not the resulting content is accessible.